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Accenture Federal Services privacy statement
July 20, 2021
Effective Date: January 1, 2023
Last updated on: October 17, 2023
Click here for information about your California privacy rights.
Click here for information about your rights as a resident of the European Economic Area.
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The purpose of this privacy statement is to provide consumers (“you”) with a comprehensive description of Accenture Federal Services’ practices concerning the processing of personal information. This privacy statement will be updated regularly to reflect any changes in the way Accenture Federal Services and its subsidiary ASM Research (collectively, “Accenture Federal Services,” “AFS,” or “we”) handle your personal information or any changes in laws applicable to our processing of your personal information. For information about how other Accenture entities protect personal information, please see the Accenture Privacy Policy.
Please note that our website(s) may include links to third-party websites. Those websites may have privacy statements that differ from ours. We do not accept any responsibility or liability for such third parties’ sites or practices. We recommend that you review such third parties’ terms of use and privacy notices before providing any information to such third parties. Please contact those third parties directly if you have questions about their personal information processing or their privacy practices.
Scope of this privacy statement
Accenture Federal Services understands the importance of protecting your personal information. This privacy statement explains how we protect the personal information we collect, process, and control relating to you (your “personal information”) and the rights you have regarding the processing of your personal information. This statement also explains how to exercise those rights.
This statement applies to the personal information that we collect and process from third parties (including subcontractors, consultants, suppliers, visitors, attendees of events that we host, business contacts, and website users among others).
Where information we collect from or about an individual is not specifically listed in this privacy statement, we will provide (when required by law) appropriate notice of what other information is or will be collected and how it is or will be used.
This privacy statement is comprised of the following sections:
- Information that we collect from and about you
- Why we process your information
- Data retention
- Children’s privacy
- Security and storage
- Contact us - questions, complaints, and additional information
- Additional information for residents of the European Economic Area
- Additional information for California residents
- Exercising your California Privacy Rights
Information that we collect from and about you
Categories of personal information and their sources
Accenture Federal Services may directly or indirectly collect, combine, and/or otherwise process personal information from and about you for the purposes set forth in the section “Why we process your information.” Categories of personal information collected may include the following:
| Category of Personal Information | Examples |
|---|---|
| Information Collected Directly From You | |
| Personal contact information and biographical details | Name, pronoun, contact information (e.g., email, telephone numbers, physical address), and, in some cases, gender, date of birth, age, place of birth, and social media handle or other online identifiers of a person. This also includes demographic data (e.g., income, family status, interests, pets, home ownership, health). |
| Sensitive personal information | Accenture Federal Services generally does not collect sensitive personal information (such as racial or ethnic origin, genetic and biometric data, protected health information, veteran status, etc.), unless necessary for purposes defined in this statement, when permitted by applicable law, and/or with your consent. AFS does not collect or process sensitive personal information for the purpose of inferring characteristics about individuals. (See “Why we process your information” for further details). |
| Information Collected Automatically | |
| Audiovisual materials | Photographs and/or images, including video footage captured on CCTV or other video systems when you visit our facilities, audio/video captured during marketing/public filming events/sessions, audio/video recordings from use of AFS-managed telephonic services, live workshops, and online or other events. |
| Commercial information | History and records of the products and services you have sought or obtained from AFS. |
| Marketing and research information | Identifiers (i.e., the IP address, Identifiers of devices used to access the website) and browser/web history data and preferences expressed through selection/viewing/purchase of goods, services, and content. |
| Cookies and geolocation data | Device information, such as that collected through cookies, or broad (not precise) geolocation information. (More details can be found in our policy on cookies and similar technology). |
| Personal Information Created About You | |
| Records of correspondence | If you contact us, or make postings, comments, or other content uploads to AFS websites or social media, we may keep a record of that correspondence, including any personal information you included in the communication. |
| Analytics information | Analytics and profiles of the individuals based on the data collected on them to assist in predicting and improving system and business performance, marketing analytics, and/or employee performance within AFS (i.e., skills training recommendations). |
| Information Collected from Third Parties | |
| Public online personal information | Social media handle or other online identifiers. |
| Miscellaneous personal information about you collected from our business partners and service providers who provide services on our behalf | Criminal, military, education, and prior employment information, financial and other information from service providers running background checks and pre-employment inquiries. |
Why we process your information
The word “processing” is used in this privacy statement to describe the various actions that can be taken with or on your personal information. It can include manual and automated actions. Among other things, these actions can include collecting, using, sharing, and disclosing your personal information.
Accenture Federal Services does not process your personal information unless: (i) it is lawful to do so, and (ii) we have a specific business purpose for doing so. We may process personal information to the extent necessary in one or more of the following circumstances:
Facilitating communications (i.e., emails, phone calls) with potential and actual clients and service providers; Managing and administering work activities; Establishing and maintaining work relationships with contractor, subcontractor, and consultant personnel; Fulfilling our obligations to current clients; Contacting clients regarding account-related issues and business communications, including technical notices, updates, security alerts, and administrative messages; and Marketing and enabling individuals to access and use our services.
Complying and demonstrating compliance with applicable privacy, data security, and other laws; Complying with incident monitoring, reporting, assessment, and notification requirements; Complying with regulatory requirements under federal, state, and international law; Complying with regulatory obligations, such as income tax, mandatory filing, record-keeping, and reporting obligations; and Conducting audits and complying with government inspections and other requests from government or other public authorities. To perform a task carried out in the public interest, including activities related to public health, public benefits, or insurance.
Providing customer service and support; Facilitating communications with you, including responding to your comments, questions, and requests; Recruiting-related activities and purposes; Providing information and services to AFS alumni; Authorizing, implementing and maintaining your access to AFS facilities; and Facilitating your attendance at AFS events and activities.
Administering, operating, maintaining, and securing our website, networks, and information systems; Monitoring and analyzing trends, usage, and activities in connection with our website and to conduct our business activities; Preventing, investigating, remediating and prosecuting fraudulent transactions, unauthorized access to our website and information systems, and other illegal or malicious activities; Verifying compliance with our internal policies and procedures; For accounting, recordkeeping, backup, and administrative purposes; Customizing and improving the content of our communications and website; Providing information and education; Providing, operating, managing, maintaining, improving, personalizing, and promoting our business activities, products and services; Conducting market research and marketing our products and services, unless you have objected to such processing as permitted by applicable law; Implementing, maintaining, and updating our Customer Relationship Management database; Social listening (i.e., identifying and assessing what is being said about AFS and our clients and projects on publicly- accessible social media content) to understand sentiment, intent, mood, and market trends and to modify or improve our products and services. Our goal is to gain insights in conversation trends and not to identify any individual. To do this, we monitor public conversation streams and analyze publicly available statements and other interactions on social media channels; Performing data analytics on business operations and data to gain insight into, describe, predict, and/or improve business performance within AFS and/or to modify or improve employee and user experiences (more details on how we run analytics on our website can be found in our Cookies and Similar Technology Policy); Protecting, enforcing, or defending the legal rights, privacy, safety, and/or property of AFS and its employees or agents and other individuals; Protecting the vital interests of the individual in a “life or death” situation.
If you provide us with personal information of another person, you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you their consent for sharing the information with AFS. As required and where circumstances allow, we will use aggregated, deidentified, or otherwise anonymized data (non-personal information) to accomplish certain of these purposes; but if we do not, or if we combine non-personal information with personal information, we will continue to treat it as personal information in accordance with this privacy statement.
How we share and disclose your information
We may transfer personal information to our service providers, contractors and professional advisors, public and governmental authorities, AFS companies/affiliates, or third parties in connection with Accenture Federal Services’ operation of its business, including any actual or potential corporate or commercial transaction. Such third parties may be located in other countries. Before we transfer your personal information, we will take necessary steps to ensure that your personal information is adequately protected as required by applicable data privacy laws.
For example, we may disclose personal information to third parties for other business purposes as follows:
- Service providers/vendors. Personal information may be shared with service providers that perform services on our behalf to carry out the uses of personal information described above in the section titled “Why We Process Your Personal Information.” This may include the provision of services such as payroll support, benefits, tax and travel management, employment eligibility verification, health and safety experts, and relocation companies. Most of these entities are contractually bound to use the personal information they receive only for the purposes of fulfilling their contractual obligations.
- Professional advisors. We may disclose your personal information to our professional advisors such as our attorneys, accountants, financial advisors, etc.
- Third parties in connection with business transaction. Personal information may be disclosed to third parties in relation to a corporate transaction, such as a merger, sale of any or all of our company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by an affiliate or third party, or in the event of a bankruptcy or related or similar proceedings.
- Law enforcement, regulators, and other parties for legal or contractual reasons. Personal information may be disclosed to third parties, as required by law or subpoena, or if we reasonably believe such action is necessary to:
- Comply with the law or the reasonable requests of regulators, court orders, law enforcement, or other public authorities, such as a subpoena, government audit, or search warrant;
- Comply with Diversity Equity, and Inclusion (“DE&I”) obligations;
- Manage legal claims asserted against AFS;
- Comply with a contract or as necessary to establish, exercise or defend against potential, threatened, or actual litigation;
- Protect ourselves, your vital interests, or those of another person; and
- Investigate fraud or to protect the security or integrity of our Sites or any products or services that AFS offers.
- Comply with the law or the reasonable requests of regulators, court orders, law enforcement, or other public authorities, such as a subpoena, government audit, or search warrant;
Data retention
Accenture Federal Services retains personal information only for so long as is necessary to accomplish the business purpose for which it was collected and to comply with its legal and contractual obligations. Under our record retention policy, we are required to destroy personal information after we no longer need it according to specific retention periods. These retention periods vary and are typically seven (7) years or less. However, we may need to hold personal information beyond these retention periods due to regulatory requirements or in response to a regulatory audit, investigation, or other legal matter. These requirements may also apply to our third-party service providers. When the retention period expires, we securely and responsibly dispose of that information or convert it into non-personal information by aggregating it, de-identifying it, or otherwise anonymizing it so that it does not directly or indirectly identify you and cannot, with reasonable efforts, resources, and technologies, be used to identify you.
Children’s privacy
Our website and the services we provide to our clients are not directed to or intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16 years of age, nor do we knowingly sell or share the personal information of children under 16 years of age without voluntary, affirmative and appropriate authorization. If we become aware that a child under the age of 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child under the age of 16 has provided us with personal information, please contact AFS.Data.Privacy@afs.com.
Security and storage
Accenture Federal Services uses reasonable physical, technical, and administrative security measures, practices, and procedures to protect personal information that we collect, control, store, or transmit. Although we strive to protect the information in our control, we cannot guarantee absolute security and this policy is not intended, nor should it be understood, to make such a guaranty.
Contact us - questions, complaints, and additional information
If you have questions, complaints, or concerns about this privacy statement, your personal information, or our practices concerning your personal information, or, if you wish to exercise your rights as described in this privacy statement, please contact us at AFS.Data.Privacy@accenturefederal.com or by mail to:
Accenture Federal Services
Data Privacy
800 N. Glebe Road, Suite 300
Arlington, Virginia 22203
Additional information for residents of the European Economic Area
Residents of the European Economic Area (“EEA”) have additional rights under European Regulation (EU) 2016/679 (the “GDPR”).
This section of the Privacy Notice describes how AFS protects your personal information to the extent the GDPR applies.
Your Rights with Respect To Your Data
To the extent the GDPR applies to the processing of your personal information and under the conditions foreseen in the applicable data protection legislation, you have the following rights:
- You have the right to request access to your personal information that we process.
- You have the right to obtain the rectification of any inaccurate personal information about you. Your rectification request must be supported by evidence of the inaccuracies in the data you are seeking to have corrected.
- Where we process your personal information based on your consent, you have the right to withdraw such consent at any time.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the erasure of your personal information.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the restriction of processing of your personal information.
- If you receive our marketing communications, you can change your preferences for receiving such communications by clicking the “unsubscribe” link provided in our communications or object to direct marketing, including profiling to the extent that it is related to such direct marketing, by contacting us as indicated above.
- Where we process your personal information based on our legitimate interests, you have the right to object to the processing of your personal information on grounds relating to your situation. However, you can also object to processing for direct marketing at any time without any charge or justification.
- If we process your personal information with your consent or to fulfill a contract and the processing is carried out by automated means, you have the right to receive the personal information you provided to us in a structured, commonly used, and machine-readable format and to transfer this information to another controller.
- We do not use automated decision-making processes that have a legal or similarly significant effect on you.
- To exercise any of the rights mentioned above, you can contact us with your request as indicated above. Please state clearly which right(s) you wish to exercise and provide reasons and proof to support your request, if required. We will acknowledge receipt of your request and proceed to review it. If your request is valid, we will honor it as soon as possible. In case we cannot verify your identity, we may request additional information to verify it.
If you are not satisfied with how we handle your personal information, please inform us by contacting us as indicated above. You also have the right to lodge a complaint with a competent supervisory authority.
International Transfers
In order to process your personal information for the purposes outlined above, we may transfer your personal information to others who are located outside of the EEA, including any country where we have partners or service providers.
If these recipients that process your personal information on our behalf are located in a third country for which the European Commission has not yet decided that it ensures an adequate level of protection and where derogations for specific situations do not apply, we will implement appropriate safeguards with regard to the processing of your personal information. Such safeguards may be provided by, for example:
- A contract between us and the third-country recipient that is based on the standard contractual clauses for international data transfers adopted by the European Commission; or
- Any other transfer mechanism or transfer tool that legitimizes the international transfer of your personal information in compliance with applicable data protection law.
Where we rely on appropriate safeguards for the transfer of your personal information, we will assess whether these safeguards can protect your personal information without diminishing the level of protection guaranteed in the EEA. If these safeguards cannot sufficiently protect your personal information, we will take the additional measures necessary to provide appropriate protection for your personal information. If taking such additional measures is not possible, we will not transfer your personal information to the recipient in a third country or will transfer your personal information to the extent that another mechanism justifies the transfer of your personal information in accordance with applicable data protection law. To obtain a copy of these data protection safeguards or to obtain information about their applicability, please contact us as indicated above.
Additional information for California residents
California Civil Code Section 1798.100 et seq. (the California Privacy Rights Act or “CPRA,” which amends the California Consumer Privacy Act of 2018 (CCPA)) requires us to provide the following information subject to the limitations set forth therein.
This section of the privacy statement describes the personal information AFS collects or processes about California residents, how AFS uses, shares, and protects that personal information, and what Californians’ rights are concerning your personal information that AFS collects or processes.
Supplementary details about personal information we collect from and about you
In the past 12 months, AFS has collected the personal information discussed above in the section titled “Information that We Collect from and about You.” Additionally, in the past 12 months, we have disclosed the above information with the following categories of third parties for a business purpose:
| Category of Personal Information | Categories of Third Parties to whom the information is disclosed for Operational Business Purposes | Business Purpose for Disclosure |
|---|---|---|
| Personal identifiers: Information such as your name; username; email address; phone number; mailing address; IP address; and date of birth. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | Provide website functionality and for use in recruiting practices. |
| Internet or other network activity information: Information regarding your interaction with the Online Activities and other applications; precise geolocation information; links you use or web pages you visit; other applications; network activity information; browser type; internet service provider (ISP); cookies; and mobile device information including device identifier or other information. | Affiliates; vendors; professional advisors; legal authorities, government agencies, and regulators. | To ensure compliance with company policies; to create and maintain cybersecurity controls; to ensure compliance with legal obligations. |
| Professional or employment-related information: Information such as current and prior employers and roles, skills and credentials, tenure, supervisors, professional memberships, reference information. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, compliance with our recruiting practices and procedures, the proper functioning of our business operations and improved business communications. |
| Electronic data: Information such as audio, electronic, visual, thermal, olfactory, or similar information. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, the proper and efficient functioning of our business operations and improved business communications. |
| Educational information: Information such as current and prior education and curricula, grades and performance, certification and graduation. and degrees. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, compliance with our recruiting practices and procedures, the proper functioning of our business operations and improved business communications. |
| Sensitive personal information: Information such as social security, driver’s license, state identification card, or passport number; racial or ethnic origin. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, compliance with our recruiting practices and procedures, the proper functioning of our business operations, and compliance with government and other reporting obligations. |
| Education information: | ||
| Electronic data: Information such as audio, electronic, visual, thermal, olfactory, or similar information. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, the proper and efficient functioning of our business operations and improved business communications. |
| Educational information: Information such as current and prior education and curricula, grades and performance, certification and graduation. and degrees. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, compliance with our recruiting practices and procedures, the proper functioning of our business operations and improved business communications. |
| Sensitive personal information: Information such as social security, driver’s license, state identification card, or passport number; racial or ethnic origin. | Affiliates; service providers/vendors; professional advisors; third parties in connection with contractual obligations. | To ensure the legitimate interests of the company, compliance with our recruiting practices and procedures, the proper functioning of our business operations, and compliance with government and other reporting obligations. |
Your California Privacy Rights
The CCPA also provides California residents with the following rights (subject to certain limitations on and exemptions from these rights):
- The Right to Know or Access Your Information: California law gives California residents the right to receive information about:
- The categories of personal information we have collected about you in the last 12 months;
- The categories of sources for the personal information we have collected about you in the last 12 months;
- Our business or commercial purpose for collecting that personal information;
- The categories of third parties with whom we share that personal information; and
- The specific pieces of personal information we collected about you.
- The categories of personal information we have collected about you in the last 12 months;
- The Right to Delete personal information: You have the right to request that we permanently delete your personal information, subject to certain exceptions. Upon receiving a verified request to delete your personal information, we will do so unless we are authorized by law to retain it.
- The Right to Correct Your personal information: If you find that we maintain personal information about you that is inaccurate, you have the right to request that we correct such inaccuracy.
- The Right to Opt Out of the Sale or Sharing of Your personal information: California law affords California residents a right to opt out of the “sale” of your personal information. We do not “share” your personal information as the term is defined in the CCPA. Rather, this right applies to the extent that we “sell” your personal information as that term is defined under California law. While we are generally not in the business of selling personal information, there are limited circumstances in which we share it with our clients, third-party partners, or others in circumstances that California law treats as a “sale” for which California residents have the right to opt out. This can happen when we transfer data to another company to provide us services, like analyzing how our website is performing or helping us to better understand online behavior and trends. We may also use this data to improve our products and services. Please click here or call 1-844-833-2556 (during standard office hours (Pacific Standard Time (PST); available in English only) to opt out of the “sale” of any of your personal information collected through this website. We do not knowingly sell the personal information of minors under 16 years of age.
- The Right Not to Receive Discriminatory Treatment: You are entitled to expect and receive treatment by AFS that does not discriminate against you for the exercise of privacy rights conferred by California law. Similarly, employees, applicants, and independent contractors have a right not to be retaliated against for the exercise of these rights.
Exercising your California Privacy rights
Please contact us to exercise your rights by emailing us at AFS.Data.Privacy@afs.com, contacting us at 1-833-226-2351 during standard office hours (Pacific Standard Time (PST), using our webform, or by U.S. mail at the address above. We will acknowledge your request and will do our best to respond to verifiable requests within 45 days of receipt. This process is generally free of charge. In some cases, we may require more than 45 days to respond to a request. In such cases, we will notify you of the delay within the initial 45-day window.
Additionally, we do recognize Global Privacy Control signals to the extent possible. A Global Privacy Control (“GPC”) is a browser setting that a user can set in order to send a signal to each website visited regarding the user’s privacy preferences, such as not to share or sell the user’s personal information. If your browser or browser extension has GPC enabled, we will automatically recognize that signal and opt you out of the sale of your personal information. For more information about GPC and how to implement GPC opt-out preference signals, please visit Global Privacy Control.
In order to protect your privacy and the security of your information, when you make certain kinds of requests, we will attempt to verify your identity as allowed by law. This may involve asking you to provide information that will help us confirm your identity before completing your request. We may attempt to match information that you provide in making your request with other sources of similar information. Any information you provide for this purpose will be used only to verify your identity and will not be disclosed or used for any other purpose.
You may use someone else (an authorized agent) to exercise certain of your rights. Your agent may email us at AFS.Data.Privacy@afs.com, contact us at 1-833-226-2351 during standard office hours (Pacific Standard Time (PST), use our webform, or contact us by U.S. mail to submit a request on your behalf. We are permitted to and will request, in addition to other information, proof that you provided your agent signed permission to make the request. We reserve the right to deny certain requests, including where we have a reasonable belief that the request is fraudulent.
If you choose to exercise your rights, you will not be charged by AFS different prices or provided a different quality of services in relation to your choice, nor will you be charged different prices or provided a different quality of services in relation to the collection, retention, sale, or sharing of personal information.
Do Not Sell/Share My personal information (for CA)
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